Estate of Pickard v. Commissioner
United States Tax Court
Decedent bequeathed her residuary estate to a trust in which her stepfather had a vested remainder interest which was not defeated by his prior death. The stepfather's will bequeathed his residuary estate to trusts of which his wife was the beneficiary for life and in which two charitable organizations were given vested remainders. Held, that decedent's estate is not entitled to a charitable deduction under sec. 2055, I.R.C. 1954.
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined a deficiency of $45,895.86 in the estate tax of the Estate of Claire Fern Pickard. The only question raised is whether the estate is entitled to a charitable deduction under section 2055.1
All of the facts have been stipulated and are so found.
The Ohio National Bank of Columbus is the executor of the Estate of Claire Fern Pickard. Its principal office was located in Columbus, Ohio, at the time of the filing of the petition herein. A Federal estate tax return was timely filed with the district director of internal revenue, Cincinnati, Ohio.
On June…
2Cases cited9 opinions
- Young Men's Christian Assn. of Columbus v. DavisSupreme Court of the United States · 1924
- Commissioner v. Estate of NoelSupreme Court of the United States · 1965
- Taft v. CommissionerSupreme Court of the United States · 1938
- Robert E. Jones v. Hugh F. Rivers, Donald ClemmerCourt of Appeals for the Fourth Circuit · 1964
- Continental Illinois National Bank and Trust Company of Chicago v. The United StatesUnited States Court of Claims · 1968
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Estate of O'Connor v. CommissionerUnited States Tax Court · 1977
- Estate of Armstrong v. Comm'rUnited States Tax Court · 2002
- Estate of Armstrong v. Comm'rUnited States Tax Court · 2002
- Estate of Frank Armstrong, Jr., Frank Armstrong III v. CommissionerUnited States Tax Court · 2002
- Estate of O'Connor v. CommissionerUnited States Tax Court · 1977
1 more not listed; retrieve them via the Exa API.